Dear Alan G., all,

In relation to the question regarding the 2009 RAA you formulated a while back, note that ICANN Org had already provided a response:

Alan Greenberg’s Question:

The EPDP is requesting that ICANN Org confirm that all registrars are now operating under the 2013 RAA.

The EPDP is requesting that ICANN Org provide its interpretation of the requirement under the RAA Data retention Specification 1.1 whether registrars, as part of their adoption of the 2013 RAA, are required to ensure that Registrant contact email and telephone fields are completed, or whether the phrase "shall maintain that information" (which was validly allowed to be blank at registration time) allows them to preserve any empty Registrant contact fields. If the former, is Contractual Compliance taking any action to ensure that registrars fulfill this obligation?

ICANN org Compliance Response:

Registrars are not required to collect additional contact information for 2009 Registrar Accreditation Agreement (RAA) registrations. However, registrars may be required to update existing contact information for 2009 RAA registrations when there is a triggering event under the 2013 RAA that may require them to do so (e.g., the domain name is an inbound transfer, the registrant changes, there is information to suggest the current contact information is incorrect).

This response is also posted here: https://community.icann.org/x/ahppBQ.

Please let us know if this does not sufficiently address your question. In order to ensure this issue is not overlooked during the implementation phase, would it be helpful to add a sentence along the following lines in the implementation part of the report: “As part of the implementation, consideration needs to be given to the potential impact of these policy recommendations on legacy registrations that without additional mitigation could end up with no contact information if the administrative contact is the only information currently available (this could be the case for a limited number of registrations that are still under the 2009 Registrar Accreditation Agreement)”?

Best regards,

Caitlin, Berry and Marika

Marika Konings

Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN) 

Email: marika.konings@icann.org

Follow the GNSO via Twitter @ICANN_GNSO

Find out more about the GNSO by taking our interactive courses and visiting the GNSO Newcomer pages.